John Demjanjuk v. Joseph Petrovsky
United States Court of Appeals
for the Sixth Circuit (1994)

1. The IAJLJ is a membership organization consisting of attorneys and judges in more than 32 countries around the world. Its founder was retired Justice Haim Cohn of the Supreme Court of Israel, and its Honorary President, until his death, was former Justice Arthur J. Goldberg. The American section was organized in 1983 by members of the American Jewish legal community to defend Jewish interests and human rights in the United States and abroad.
2. Among the IAJLJ's concerns has been the identification and legal prosecution of those who participated in the genocide of the Jewish people during the Second World War. Our interest extends beyond the punishment of particular guilty individuals. The IAJLJ believes it essential that history acknowledge the culpability of the guilty and record their punishment so that mankind will never again experience such unbelievable brutality and wanton murder.
3. It is appropriate that the Court hear in this case not only from the immediate parties to the controversy before it but also from counsel who can attempt to speak on behalf of the victims of the criminal conduct that underlies these proceedings. In the enclosed memorandum, counsel has endeavored to describe some of the concerns expressed by survivors of the Holocaust.
4. The American Section of the IAJLJ filed an amicus curiae brief in this case in August 1992, but we could not know until the Petition for Rehearing and for Rehearing En Banc was filed and reviewed whether the concerns expressed in the enclosed amicus memorandum would be presented to the Court by the parties. on reviewing the briefs as filed, we determined that it would be appropriate to submit the enclosed memorandum on behalf of the American Section of the IAJLJ.
5. Since the Federal Rules of Appellate Procedure do not provide for the filing of any response to a Motion for Rehearing En Banc except upon order of the Court, Demjanjuk would not be prejudiced by the Court's consideration of the memorandum at this time. If the Court deems a response appropriate, Demjanjuk will have the same amount of time to respond to this memorandum as he has to respond to the government's Motion.

For the foregoing reasons, we respectfully request leave to file the enclosed Memorandum Amicus Curiae.

	Respectfully submitted,
INTERNATIONAL ASSOCIATION OF JEWISH LAWYERS AND JURISTS (American Section) Suite 702 1828 L Street, N.W. Washington, D. C. 20036 (202) 775-0991	NATHAN LEWIN MILLER, CASSIDY, LARROCA & LEWIN 2555 M Street, N.W. Washington, D. C. 20036 (202) 293-6400 Attorney for the Amicus Curiae

January 1994